Policy Priorities
Our Priorities
As the voice of the long-term care pharmacy community, SCPC’s policy priorities reflect the unique needs of our members and the patients they serve. LTC pharmacies play an essential role in our health care system—one that is significantly different from and often more complex than that of a typical retail pharmacy. Policy and regulations must reflect these differences.
Our advocacy efforts consider the diverse settings in which LTC pharmacies operate, including skilled nursing facilities, assisted living facilities, hospice, and home.
SCPC’s develops its policy priorities based on the needs of LTC pharmacies around the country and the interests of the patients they serve. Our top priorities include:
1
Establishing a sustainable payment model for LTC pharmacies.
2
Reforming abusive PBM practices to protect LTC pharmacies and the patients they serve.
3
Defining long-term care pharmacies at the federal level.
4
Ensuring access to essential LTC pharmacy services for LTC patients wherever they live.
Establishing a Sustainable Payment Model for LTC Pharmacies
Lowering drug prices shouldn’t unintentionally limit seniors access to essential pharmacy services. LTC pharmacies provide specialized services for vulnerable patients in long-term care. But without a critical fix to the broken LTC pharmacy payment model before January 1, 2026, many will not survive.
The Problem: New policies included in the American Rescue Plan and Inflation Reduction Act intended to lower drug prices unintentionally threaten the future of many LTC pharmacies and the millions of vulnerable patients they serve. Given the way Medicare Part D Plans and PBMs force LTC pharmacies to subsidize inadequate payment for their specialized services with revenues from expensive brand-name drugs, these policy changes inadvertently break the LTC pharmacy payment model. LTC residents rely heavily on insulin, inhalers, and 8 of the first ten drugs subject to Medicare-negotiated prices, leaving LTC pharmacies to face unsustainable financial losses from dispensing these medications.
The Solution: Congress must pass the LTC Pharmacy Fix to address these unintended consequences and save senior Rx care. The LTC Pharmacy Fix, which includes the creation of a new LTC pharmacy supply fee and specific PBM reforms, will ensure that Medicare Part D payments for LTC pharmacy services better reflect the actual cost of essential and legally required services. This commonsense solution will also address both the problem of inadequate dispensing fees and the problem of unfair contracts and predatory market practices driven by disproportionate PBM market power.
Resources
Documents
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One-Pager: New Report Shows Congress Must Fix Broken LTC Pharmacy Reimbursement Model
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2024 Analysis: Long-Term Care Pharmacy Cost Analysis
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Issue Brief: Long-term care (LTC) pharmacies deserve fair payment and a level playing field to negotiate with PBMs. This is the only way to assure essential pharmacy services for the millions of Americans who rely on long-term care.
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White Paper: The Impact of Drug Price Negotiations on Seniors in Long-Term Care
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Media Statements
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SCPC Highlights Devastating Impact on Medicare Drug Price Negotiations on LTC Pharmacies
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Fair and Transparent PBM Practices
Regulating PBMs and protecting independent LTC pharmacies
Problem: PBMs engage in predatory business practices including opaque and unjustified fees for pharmacies and market consolidation across the pharmacy, distribution, insurance and healthcare provider sectors. Both practices can delay medication access, increase consumer costs, and force LTC pharmacies and other independent pharmacies to go out of business or sell to the PBM.
Solution: Congress must pass legislation that requires transparency in PBM drug pricing information and provides stronger regulations for CMS to hold PBMs accountable. Congress should also thoroughly investigate PBM business practices for violations of antitrust laws.
Resources
Issue Brief
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Long-Term Care Pharmacies believe patients deserve affordable, cccessible medication; Pharmacy Benefit Managers put profit over care and refuse transparency
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SCPC Comment Letters
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Letter to CMS - Maximum Monthly Cap on Cost-Sharing Payments Under Prescription Drug Plans: Draft Part One Guidance on Select Topics, Implementation of Section 1860D-2 of the Social Security Act for 2025, and Solicitation of Comments
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Letter to the FTC - Comments on the Impact of Prescription Benefit Managers’ Business Practices May 25, 2022
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Letter to CMS - Medicare Program: Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefits Programs March 7, 2022
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Letter to CMS - Advance Notice of Methodological Changes for Calendar Year (CY) 2023 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies March 4, 2022
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Other PBM Comment Letters
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Federal Definition of LTC Pharmacy
Defining long-term care pharmacies at the federal level
The Problem: Current federal regulations impose conflicting and confusing obligations on LTC pharmacies. Because the federal government has not formally defined a “long-term care pharmacy,” major discrepancies exist among regulatory bodies such as CMS, EPA and FDA when it comes to the patient care services LTC pharmacies provide.
The Solution: Congress must pass legislation to modernize regulatory oversight of LTC pharmacies and adopt a specific federal definition of “long-term care pharmacy.” A federal definition will allow LTC pharmacies to continue providing high-quality, essential care for LTC patients.
Resources
Issue Brief
Long-Term Care at Home
Ensuring LTC pharmacies’ role in the expanding home-based services and support
The Problem: As our population continues to age, LTC pharmacies provide wraparound clinical and consulting medication management services that keep people who need long-term care in the places they want to be – including their own homes. Public policy and regulations have not kept up with the rise in demand for LTC pharmacies and the crucial services provided to this population.
The Solution: To ensure the best outcomes for LTC patients, SCPC supports the creation of a federal payment platform that appropriately funds LTC pharmacy services, no matter the setting, so patients with long-term care, social, and supportive needs can still live at home in their community if they choose.
Resources
Issue Brief
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Long-Term Care Pharmacy Services are Essential to Effective Expansion of Medicaid-Funded Home and Community-Based Services (HCBS)
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